Mn Dossier update - CSR submitted Jointly

Manganese metal REACH dossier faced extensive updates during the year 2021. Following demands from ECHA and in order to understand post 2010 co-registrants use and exposure patterns an extensive survey was launched and a registration update was submitted on 21 September 2021 to align with this new/uptodate information - this submission was rejected with feedback from ECHA mainly focussing on unaccaptable Bioaccumulation waiver.

ECHA's concerns were addressed and the dossier re-submitted - this second submission was accepted by ECHA on 7 December 2021.

Furthermore, a proposal was made by some co-registrants for the Lead registrant to submitted a joint CSR. After examination of the proposal by the Manganese REACH Administration (MARA) Board it was considered more convenient for co-registrants if the CSR was formally included as part of the joint submission. Hence a further update was concluded on 8 December 2021.

We consider that the jointly submitted CSR covers the vast majority of common uses of manganese metal in the EU but registrants should check carefully to make sure that their own uses are covered. Registrants with niche uses may need to complete their own CSR to cover the said use.

The cost associated to all the above mentioned updates will be recalculated in the reimbursement model and a top-up invoice or credit note ( as the case may be) will be issued to all registrants.

We do not anticipate doing any more work on  the Mn metal dossier during over 2022 unless ECHA request further information. 

In case of questions on the CSR please contact reach@manganese.org